Litigator's Guide to Metadata - Codemantra.net

Note: Though frequently large in size, these file types rarely contain significant textualcontent and so rarely warrant use of the more costly methods needed to process text-richfile formats for production.d. The file types listed in a. and b. above must be identified and considered in searching forpotentially responsive ESI; however, this is not an exclusive list of all potentially responsivefile types. Parties are expected to apply their knowledge of information systems andapplications used by employees when seeking to identify potentially responsive file types,as well as to make a reasonably diligent search for responsive file types not listed.e. Parties may exclude from production all files customarily found in folders reserved to―Temporary Internet Files‖ with the exception of the contents of Outlook ―OLK‖ folders.III.Unique Production Identifier (UPI)a. Other than paper originals and images of paper documents (including redacted ESI), noESI produced in discovery need be converted to a paginated format nor embossed with aBates number.b. Each item of ESI (e.g., native file, document image or e-mail message) shall be identifiedby naming the item to correspond to a Unique Production Identifier according to thefollowing protocol:i. The first four (4) characters of the filename will reflect a unique alphanumericdesignation identifying the party making production;ii. The next nine (9) characters will be a unique, sequential numeric value assigned tothe item by the producing party. This value shall be padded with leading zeroes asneeded to preserve its length;iii. The final five (5) characters are reserved to a sequence beginning with a dash (-)followed by a four digit number reflecting pagination of the item when printed topaper or converted to an image format for use in proceedings or when attached asexhibits to pleadings.iv. By way of example, a Microsoft Word document produced by Acme in its nativeformat might be named: ACME000000123.doc. Were the document printed out foruse in deposition, page six of the printed item must be embossed with the uniqueidentifier ACME000000123-0006.IV.E-Mail and Attachmentsa. Form of Productioni. E-mail from Exchange/Outlook environments will be produced in the single messageMAPI-compliant MSG format. Messages in webmail, Lotus Notes or GroupWiseformats shall be converted to the MSG format with care taken to, as feasible,preserve as discrete fields the information listed in VI(c)(x) through (xxi).30